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Mr. ORLANS. It is not just Nova. After all, Nova is an accredited institution, and some of the best established institutions are now offering nonresidential credit and degrees under the leadership of the educational establishment, the Carnegie Corp.-the problem is widespread and by no means confined to unaccredited institutions.

Senator PELL. How do you think we establish a balance, both in proprietary schools and in the external degree programs, between that which is good in them, because there is good, particularly in proprietary schools, which are educating people to cope with the problems of earning a living, and also at the same time preventing the abuses in the fly-by-night aspects of it?

Mr. ORLANS. I have no real solution to this problem.

I think that the institutional accrediting agencies have not maintained standards, and the proprietary accrediting agencies are much newer; if the regional accrediting commissions are unable to maintain quality standards, I do not see that we can reasonably expect any more of the proprietary agencies.

The notion of standards really was dealt with by De Tocqueville. They have given way to the equality of all schools and of all programs which they offer. Insofar as they are definable and meaningful educational standards, they are defined by conservative professional associations which use the standards to maintain a monopoly over entrance into lucrative professional practice.

Senator PELL. I thank you very much. I appreciate your candor. The purpose of these hearings is concerning the abuse on one hand and making education available to more people on the other hand. We hope out of this will come at least some changes in direction or policy developments.

I thank you very much.

The hearing is recessed until 10 o'clock tomorrow morning.

[Whereupon, at 11:00 a.m., the subcommittee recessed, to reconvene at 10:00 a.m., Friday, Sept. 13, 1974.]

41-997 - 75 - 15

ACCREDITATION OF POSTSECONDARY EDUCATION

INSTITUTIONS, 1974

FRIDAY, SEPTEMBER 13, 1974

U.S. SENATE,

SUBCOMMITTEE ON EDUCATION OF THE

COMMITTEE ON LABOR AND PUBLIC WELFARE,

Washington, D.C.

The subcommittee met, pursuant to recess, at 10:03 a.m., in_room 4232, Dirksen Senate Office Building, Hon. Claiborne Pell (subcommittee chairman), presiding.

Present: Senator Pell.

Committee staff present: Stephen J. Wexler, counsel; and Roy H. Millenson, minority professional staff.

Senator PELL. The hearing of the Subcommittee on Education on the subject of accreditation will reconvene.

Yesterday we had a most productive and informative session with the Department of HEW, and a very candid discussion of the problem with Dr. Harold Orlans, Senior Research Associate, National Academy of Public Administration Foundation.

Today we will be hearing from representatives of private accreditation agencies themselves, explaining what their function is, how they accomplish their aims, and, ultimately, how they perceive their own role in the Federal scheme.

Our first witness is a panel representing the so-called nonprofit academic accreditation groups, comprised of Frank G. Dickey, Ph. D., executive director, National Commission on Accrediting, and Robert Kirkwood, Ph. D., executive director, Federation of Regional Accrediting Commissions of Higher Education. Would you come forward, please?

STATEMENT OF FRANK G. DICKEY, PH. D., EXECUTIVE DIRECTOR, NATIONAL COMMISSION ON ACCREDITING, AND ROBERT KIRKWOOD, PH. D., EXECUTIVE DIRECTOR, FEDERATION OF REGIONAL ACCREDITING COMMISSIONS OF HIGHER EDUCATION, A PANEL DISCUSSING NONPROFIT ACADEMIC ACCREDITATION Mr. DICKEY. Mr. Chairman and members of the staff and Subcommittee on Education, I am Frank G. Dickey, executive director of the National Commission on Accrediting.

The National Commission on Accrediting is a private, nongovernmental association of some 1,200 institutions of higher education that

banded together in 1949 through the associational mechanism to monitor and coordinate the existing and emerging programs of accreditation for professional and specialized education in this Nation.

I appreciate the opportunity to present this testimony and even though time may preclude the inclusion of the entirety of this written statement in my oral presentation, I request that the entire written statement be entered into the record of these hearings.

During this summer several congressional subcommittees have held hearings relative to the relationship of accreditation and eligibility for Federal funding. The vast majority of the witnesses appearing at these hearings have expressed the belief that the Federal Government should not continue to rely as heavily as they presently do upon accreditation as the almost sole determinant of eligibility for Federal funds. Accreditation was not designed or developed to serve this particular purpose.

The accrediting agencies did not seek this function; rather, it was assigned to them by congressional action; however, in doing so, Congress did not intend that the nongovernmental accrediting organizations should become subject to a set of criteria that now are forcing the accrediting agencies to conform to certain Federal criteria and also to perform tasks that take on the flavor of policing functions not compatible with the work of voluntary associations.

More specifically, accrediting organizations have been enticed to become reluctant extensions of the U.S. Office of Education in order that the accredited schools, programs, and colleges might share in the largesse writ large. Many would now like to break off the relationship, and some have indicated they intend to do so, in order to return to the prerogative which historically and professionally has belonged to them-that of promoting and insuring quality programs of education. All are capable of doing just that and are perfectly willing to abide the scrutiny of the Federal benefactor in so doing. They are not willing much longer to abide the prod which inevitably has followed the scrutiny.

If, as I believe Congress originally intended, there is to remain the partnership relationship between the U.S. Office of Education and the private accrediting bodies in this country, then the Federal body is going to have to quit presuming the majority stockholder attitude in the enterprise.

Let me say that accreditation and accrediting bodies have not been put upon altogether unjustifiably since 1952 when the Commissioner of Education began to rely upon them as the primary determinant of eligibility for Federal funds.

I will say, that in my opinion, the accreditation community has moved much faster in correcting some deficiencies and establishing its capability to speak for eligibility based on quality than has the Federal mechanism in establishing any valid system for determining eligibility for institutions outside the prerogative of accrediting bodies. That really is where most of the current abuse we read about resides.

And, the accrediting bodies can yet go some further, perhaps, in incorporating some of the needed consumer interests into their evaluating processes. They cannot and should not go much further

in the direction of acting as enforcers of social policy such as affirmative action, health and safety standards, or collective bargaining agreements.

Here I would like to explain that it is not that accrediting bodies are not favorably inclined toward all of these things, but as I have indicated before, the accrediting bodies feel that they are voluntary agencies, and should not be in the business of policing and enforcing social policy that emanates from certain legal actions.

The time has come, in our opinion, for the legislation relating to the determination of institutional eligibility for Federal funds at the postsecondary level to be revised or amended in such a manner that other factors in addition to accreditation should be utilized in determining eligibility.

After I had presented testimony to another congressional subcommittee earlier this summer some of my colleagues indicated that they believed I had sounded the death knell for nongovernmental accreditation and eligibility functions for purposes of Federal funding. They pointed out that if my suggestions were to be taken seriously by the U.S. Office of Education the Federal Government would establish a parallel system of accreditation by another name with a giant bureaucracy to administer it.

This was not what I had in mind and I should hope that the thousands of institutions in this Nation would resist such a move if it should occur. I assure you that the private accrediting community would do so.

My earlier proposal, stripped of any fancy language, was simply that the Federal Government should rely on accreditation as a significant criterion in determining eligibility for Federal funding, as was originally intended by Congress, but at the same time, the Congress should introduce its own, simpler system, for ascertaining the eligibility for the myriad of programs and institutions.

I wish to emphasize for this subcommittee, as I did for the earlier committee, that accreditation should not be expected to serve as collateral for, nor procurer of Federal funds for institutions, programs, or individual students. Accreditation can and does speak to the consumer up to a point and that point is that the institution or program is providing the very best quality it is capable of providing, given its human and financial resources. But, accreditation cannot authorize the establishment of institutions, nor can it force them to cease to operate. It can only work to help improve those institutions in existence that sincerely seek consultation and services.

Accreditation has served education in this Nation most effectively for more than half a century and it is willing to continue doing so, if it is allowed to operate within its capabilities and voluntary param

eters.

It should be pointed out that accreditation cannot be a surrogate ministry of education in a nation where the founding fathers clearly guarded against such a structure; nor can accreditation serve as a protective agency to respond to every consumer complaint.

You may well ask what the alternatives are for determining eligibility if we do not use accreditation as the sole determiner. May I suggest that there are two or three other sources of assistance that

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